Douglas W. and Gail Caple - Page 10




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          of “$18,000 in tax credits”, and (3) petitioners’ expected                  
          “future tax benefits.”  Petitioners attached five typed pages to            
          their Form 656 explaining their OIC.  In the attachment,                    
          petitioners stated that their OIC was reasonable in the light of            
          their protracted dealings with respondent since 1996 and Mr.                
          Caple’s and Ashley’s extensive medical ailments and the costs               
          associated with their care.                                                 
               On September 22, 2004, respondent rejected petitioners’ OIC            
          on the grounds that petitioners had failed to substantiate their            
          hardship and that they had sufficient assets to pay the amount              
          owed.                                                                       
               On October 27, 2004, respondent issued petitioners a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320, in which respondent determined the notice of Federal tax              
          levy for taxable years 1993 and 1994 to be proper and determined            
          that collection of the tax liabilities for those years should               
          proceed.                                                                    
               On June 26, 2006, respondent issued another notice of intent           
          to levy.  Petitioners filed a “Petition for Redetermination of a            



               10(...continued)                                                       
          for $12,000 an antique Porsche that in 2004, had a fair market              
          value of $9,000, and that in 2004, they sold for $14,000 a motor            
          boat that they had owned for several years.  Petitioners maintain           
          that they “refunded” the proceeds from the sale of the boat to              
          Ashley, because they had previously “borrowed” $14,000 from her             
          college fund.                                                               






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